80. Will the introduction of CAPPA be part of
the solution or just another part of the problem?
(Mr Gardiner) I very much hope that it will be part
of the solution. We need to take every possible step to avoid
it becoming a further problem. Earlier this morning reference
has been made to the fact that the Government's record on major
computerisation is not fantastic. Throughout the process which
has led to the formation of CAPPA we have pressed very hard for
sufficient money to be given to the system, and also outside expertise.
In fairness to the system as it is run, one must remember that
the European rules have changed every year, often in very significant
ways. However, when one has an inflexible database trying to run
after rule changes one has enormous problems. CAPPA and those
who work for it will need to understand that further massive rule
changes in the IACS system are all too likely. It is no good producing
a specification for software which fits today; it must fit tomorrow,
which is not entirely predictable.

81. A key recommendation would be that, for
heaven's sake, one should make sure that the system is capable
of accommodating quite significant changes?
(Mr Gardiner) Absolutely. It should include quite
major things, such as the introduction of the dairy industry in
future with dairy cow payments.

Mr Todd

82. You touched briefly on the possibility that
other countries had invested more in the application of technology
or fundamental data collection to aid the process of administering
the process. Have I correctly understood it?
(Mr Bennett) That is one of our impressions. One of
the few elements of confirmed knowledge from other Member States
is that there is much greater investment in IT in most other countries.
That stems from earlier operation of cattle databases through
to much more sophisticated IT, for example IACS. The French seem
to be in front of us in simplifying the system for their farmers.
Most other European Union countries appear to realise that when
they put together databases it is useful to talk to one another;
if they do, it means that they can reduce it to one inspection
instead of four or five. We could learn a little from the way
that other countries in Europe have operated.

83. You listened to my line of questioning about
CAPPA. Clearly, other models could have been looked at to see
how we could move to a process which correctly identifies our
cattle and manages the grant implications. Do you think that generally
enough is done in the UK to look at other models before we march
blithely into the future?
(Mr Bennett) I believe that MAFF spent considerable
time looking at what others had done in creating a cattle database.
Mention has been made of the Dutch. I believe that the Department
spent some time looking at all the other operations before it
set up Workington in 1996.

84. The Department may have looked at it but
do you think that it learnt anything?
(Mr Bennett) It was a very difficult operation to
set up. Certainly, it learnt a number of things, and there are
some further matters to be learnt.

85. You said that in the past perhaps the problem
was lack of investment. Is it also lack of imagination, competencies
and a willingness to compare with others before moving ahead?
On the basis of that example, you say that it did?
(Mr Bennett) There is no doubt that money plays a
big part. As has been indicated already, when Government starts
to invest in IT systems they tend to do it to cost rather than
decide that that is the system that they want for which they must
pay. One fault line is that they tend to decide, for example,
that a cattle movement database is required without thinking through
how that system is to operate in future and is to be linked with
the support schemes. If there is one criticismperhaps this
is unfair because I am looking from the outside init is
that possibly there is a need for a strategic plan to operate
across the whole concept, not just cattle movement database, on
which a decision can be taken.

86. Do you think that as to that our response
is disastrous, in that we have said we must do this for the control
of BSE and have bolted on some other elements without first thinking
it through?
(Mr Gardiner) Another point arises on the split between
the capital cost of the cattle tracing service which is to be
met by Government and the running costs which are to be met by
the industry. There is always a temptation in Government to allow
a more complicated system to operate for which the industry pays
rather than put money up front for development. Certainly, all
the way through the industry group which looked at cattle tracing,
of which we form part, pressed for the more rapid implementation
of electronic alternatives, while recognising that it would be
difficult for some farmers. We saw that as simplifying the whole
process. One of the major problems is transcription errors from
farms to claims and reading errors in entering the claim in Workington.
With the best will in the world, those will continue. Farmers
will still write slightly obscurely and someone in Workington
will misread it. Unless one gets closer to an electronic system,
these problems will persist and add to the running costs and strain
on individual farmers.

87. You mentioned the difficulties in obtaining
comparative information in Europe, although the forms are readily
obtainable. Is not a large part of it the difficulty of understanding
the different cultures of administrationI see you nodand
trying to identify, not what appears on a piece of paper, but
the way in which officials interact with the community with which
they are supposed to work? Is not one of the most critical aspects
to look at the fact that the bureaucratic mind is less suited
to this task than the mind of some other Member State officials?
(Mr Bennett) There is a variation across the Community
in terms of officials. Some countries have almost as many officials
as farmers, so in a sense there is a good deal more advice available
on the forms. I believe that we get good back-up for the number
of officials employed by MAFF.

88. There are armies of people at some Regional
Service Centres.
(Mr Bennett) If one goes to the Republic of Ireland
there is a distinct variation in the number of people employed,
but there are cultural differences in how these matters are approached.
It is interesting that the Commission itself, which effectively
administers these schemes for the Court of Auditors, has never
come up with standards of best practice in different Member States,
which would probably be beneficial.

89. That cultural difference is perhaps worth
some exploration. We should not necessarily take the view that
the British way is best because that is the way we are used to
doing things. Before you came in, I drew rather harsh comparisons
with the colonial world and how civil servants in this country
had traditionally behaved. Is there at least the possibility of
scrutinising the culture of different bureaucracies and how they
apply these tools to achieve the outcome that we seek?
(Mr Bennett) I certainly believe that further investigation
as to how other countries implement the schemes is warranted.
But the fundamental stumbling block in terms of the UK is that
our officials are probably more frightened of the Treasury and
disallowance than those in any other Member State.

Dr Turner

90. Have you done any work to check one of the
simpler measures of difficulty: how long it takes the average
farmer to complete the IACS form? Have you carried out any investigatory
work?
(Mr Bennett) We have not run a survey of our members
as to how long it takes them to fill in the form. Perhaps Mr Raymond
can tell you how long it takes him to do it.
(Mr Raymond) As far as the IACS form is concerned,
it probably takes anything up to two or three days. That is time
that could be spent on managing the farm rather than form-filling.

91. Do you agree that if you have some measure
of how long it takes then, as you move towards electronic forms,
or changing the forms, possibly you have a check on whether things
are getting better or worse?
(Mr Bennett) When one fills in various forms MAFF
occasionally runs a survey in which it asks the farmer how long
it takes him to complete the form. That is probably a random survey,
because I do not have it every year. Certainly, this year I was
asked to monitor how long it took me and then to report back.
Therefore, MAFF must itself be looking at the time taken to fill
in the form.

92. Given that it takes two or three days to
do it during which the farmer should be doing something else,
do you see a role for a professional agency? Would the time saved
by the farmer be worth the cost of employing somebody else to
cope with the paperwork, in the same way that some people hand
their tax affairs to accountants?
(Mr Bennett) Quite a lot of our members already use
professional agents to fill in their forms because they then feel
a good deal more confident about it. I am not aware of the percentage,
but I am aware of a good number of farmers who hand it over to
agents.

93. Does anyone know what the typical cost would
be to the farmer?
(Mr Bennett) Obviously, it depends on the size of
the form, but if the process takes two days one is talking of
a few hundred pounds.
(Mr Raymond) It would probably be a bit more; it might
go into four figures if one employed a professional person for
two or three days. Obviously, one of the challenges that we identified
when we prepared the report was the possibility of electronic
form filling becoming the norm, with the completion of the GIS
mapping exercise. We studied the system in the Republic of Ireland.
There is no doubt that the system in that country is far simpler
than ours, because a lot of the work has already been done. Farmers
were given preprinted forms and all they needed to do was update
them rather than start afresh, as appears to be necessary in this
country. The challenge is to get the mapping completed and get
as many farmers as possible down the electronic route.

94. Before we leave the forms, how clear is
the advice? If one were asked to rate the current forms for clarity
and the advice given on a scale of zero to 10, where would they
be at the moment? Hopefully, we shall some of the others to make
comparisons.
(Mr Raymond) I suggest that it is a good deal better
now than it was three or four years ago when we first had to go
through the procedure of filling in the IACS forms. A good number
of farmers are infuriated by the fact that if they make a clerical
error they can be penalised. However, sometimes when the previous
year's information is passed back to the farmer it may contain
clerical errors.

95. Perhaps I may pin you down. I am an engineering
scientist by training and like to quantify things where I can.
For clarity, what score would you give the forms now out of 10?
(Mr Gardiner) I should declare that we give them some
advice before it is designed, and each year's form is tested on
farmers before it is finalised. However, one must remember that
the form chases a system which becomes more complicated every
year. The words "CAP simplification" have been thrown
around for the past five or six years, but when one comes to the
farm operation and the filling up of the forms to get support
payments there has not been simplification but complexity piled
upon complexity.

96. There are two processes here. I believe
that you have correctly identified that the problems arise on
the rules and procedures. Clearly, that is an issue to be addressed.
At the same time, we are concentrating on the complexity of the
system which is similar in other countries. You have alluded to
greater simplification in Ireland. Perhaps you would give Ireland
a score nearer 10. I am trying to gauge where you believe we have
reached in administering the European system and making it clear
to farmers what the rules are and how to fill in their forms accordingly.
In a moment I shall give in if you do not give a number. Assuming
that the Irish are somewhere near the top, where do you think
we rank in terms of clarity?
(Mr Bennett) To make one caveat, probably each of
us would give a different score. There has been a big improvement
in the score. I hear a number to my left which is one that I would
not give. I believe that the situation is improving, and so perhaps
I give a score of seven.
(Mr Pearce) I would rate each of the individual schemes
quite highly, but that is not necessarily the problem. The difficulty
is that the dynamics of our industry are such that people claim
under more than one scheme. The problem is the interaction between
the schemes and the relationship, particularly in livestock, with
IACS. Given the overall complexity of the system, my score would
be considerably lower than the one just given.

97. I am not talking about the complexity of
the system but how well they do the job in providing the information
needed and explaining what must be filled in.
(Mr Bennett) The important point here is that there
is a genuine desire to improve clarity and make a very complex
system as simple as possible. There have been improvements but
there is a long way to go. I believe that, therefore, the score
I give is a fair one.

98. Do I take it from your comments that you
have been consulted this year on what the forms should look like
next time round?
(Mr Bennett) Yes. The Department consults us on all
scheme forms before they go out.
(Mr Gardiner) This year we had important changes in
the hill support system. Therefore, this year's form will look
a lot more complicated to our hill farmers than last year's, however
well one seeks to deal with it in the explanatory notes. It is
all new, and is rather like one's income tax form changing every
year in a major way. An income tax form is incredibly complex
and contains huge numbers of boxes with masses of explanatory
notes but, luckily, this year's looks very much the same as last
year's.

Chairman

99. The more we go towards a discretionary element
in the CAP schemes, and the more the Government try to introduce
environmental criteria into the payments, presumably the more
complex the forms?
(Mr Bennett) That is one of the concerns. When one
introduces national discretion there is a tendency to devise another
scheme; for example, the national envelope facility within the
beef scheme. One could end up devising another scheme with a different
stocking rates. Within the various schemes the producer has up
to five stocking rates with which he must cope across all the
schemes, from the hill farming scheme to countryside stewardship.
The complexity becomes greater. Therefore, when Member States
have discretion one of the key decisions to be taken is to reduce,
not increase, complexity. We do not see evidence of that at the
moment.